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RYAN v. DEPARTMENT OF REVENUE

No. 404.

68 Wis.2d 467 (1975)

228 N. W. 2d 357

RYAN and wife, Appellants, v. DEPARTMENT OF REVENUE, Respondent.

Supreme Court of Wisconsin.

Decided May 6, 1975.

Attorney(s) appearing for the Case

For the appellants the cause was submitted on the brief of Robert E. Sutton and Samson, Friebert, Sutton, Finerty & Burns, all of Milwaukee.

For the respondent the cause was submitted on the brief of Robert W. Warren, attorney general, and Sverre O. Tinglum, assistant attorney general.

Submitted under sec. (Rule) 251.54 April 10, 1975.

BEILFUSS, J.

The appellants contend, due to the representation of the woman at the commission to the effect that she would file the petition, and due to the appellants' allegedly justifiable reliance to their detriment upon such representation, that the department is estopped from asserting the untimeliness of the filing of the petition.

We hold that estoppel is inappropriate here because: (1) It is...

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